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“Such operations, albeit not purposeful, may impugn the company’s reputation and potentially subject Evolution to heightened regulatory scrutiny and the imposition of sanctions,” the report continues.
In the dossier, Spectrum unpacks Evolution’s review and vetting processes for potential clients. At the time of the report, Evolution required clients to provide certification of the beneficial ownership of 25% or more of the company. But Spectrum says it was not using “a viable process” as some documents provided by companies could be inaccurate.
“If red flags become known to Evolution during this onboarding process, Evolution should either determine not to do business with the company or undertake enhanced due diligence to resolve the red flags before engaging in business with the company,” Spectrum advises.
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The press release also warned operators against complying with any payment requests from departments that aren’t legally authorised to do so.
It called for any such acts to be reported immediately to the Ministry of Finance and the Directorate General of Administrative, Judicial, State Property and Equity Revenues (DGRAD).
The DGRAD has been tasked with identifying and securing the cancellation of any irregularly issued payment notices.
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Operators may not use data from individuals who have self-excluded, are undergoing treatment, or have requested to block marketing in order to attempt to reactivate them. Repeated or intrusive messages and offers directed at users who have reduced their gaming frequency, registered significant losses, triggered limits or shown signs of risky behaviour are also prohibited.
The text also bans exploiting situations of economic crisis, unemployment, debt, emotional distress, grief, anxiety, depression, loneliness, or other conditions of vulnerability to attract, retain or reactivate gamblers.
Operators must maintain permanent mechanisms for age verification, self-exclusion, voluntary time and wagering limits, and information on the user’s own gambling behaviour. Self-exclusion must be effective with all authorised operators.
